Association Comments on CY 2026 PFS Proposed Rule

In a Sept. 12 letter to the Centers for Medicare & Medicaid Services (CMS), America's Essential Hospitals responded to the agency's proposed annual update to the Physician Fee Schedule (PFS) and other major policies. The association urged CMS to support essential hospitals through the creation of an essential hospital designation and additional adjustments to the proposed rule.

Specifically, the association urged the agency to:

• Withdraw proposed changes to practice expense relative value units for facility-based settings, which would destabilize safety net providers and threaten patient access
• Finalize proposals to expand access to telehealth, including simplifying the Medicare Telehealth Services List and codifying direct supervision via real-time audio/video, while maintaining parity for resident supervision across all settings
• Finalize add-on codes for advanced primary care management services related to mental health services
• Rescind the proposed "efficiency adjustment" to select payment codes
• Preserve flexibility for safety net participation in value-based care models, including maintaining the current glide path for one-sided risk in the Medicare Shared Savings Program
• Protect the 340B Drug Pricing Program by finalizing a voluntary, claims-based repository for identifying 340B claims while ensuring confidentiality, retrospective claim identification, and adequate testing before any mandatory use

Contact Director of Policy Rob Nelb, MPH, at [email protected] or 202.585.0127 with questions.